Rozella Simmonds and Jeff Simmonds, Petitioners v. Edward Parks and Bessie Stearman, Respondents, and State Of…

Summary

The court held that Parks and Stearman could not collaterally attack the Minto Tribal Court's termination judgment in state court because they failed to exhaust available tribal appellate remedies. It adopted the federal exhaustion doctrine for ICWA-defined child-custody proceedings, concluded that no exception applied because tribal jurisdiction was at least colorable and plausible, and therefore required Alaska courts to give the tribal judgment full faith and credit. The court reversed and remanded for dismissal of Parks's state-court action with prejudice.